**Document:** Officer Report
**Application:** 24/91146/B — Redevelopment of an existing Sure Mobile site that will consist of replacing the current monopole with a new 15 meter slimline lattice with multiple mobile panel antennas/dishes/radio kit with associated ground equipment cabinets and boundary fence.
**Decision:** Permitted
**Decision Date:** 2024-12-02
**Parish:** Lezayre
**Document Type:** report / officer_report
**Source:** https://planningportal.im/a/33424-lezayre-sure-mobile-site-replacement/documents/1076832

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# Officer Report

## PLANNING OFFICER REPORT AND RECOMMENDATIONS

**Application No.:** 24/91146/B
**Applicant:** Sure (Isle Of Man) Ltd
**Proposal:** Redevelopment of an existing Sure Mobile site that will consist of replacing the current monopole with a new 15 meter slimline lattice with multiple mobile panel antennas/dishes/radio kit with associated ground equipment cabinets and boundary fence.
**Site Address:** Sure Mobile Site Shipyard Road Ramsey Isle Of Man IM8 3DT Senior
**Planning Officer:** Jason Singleton
**Photo Taken:** 14.11.2024
**Site Visit:** 14.11.2024
**Recommended Decision:** Permitted
**Date of Recommendation:** 25.11.2024 _________________________________________________________________

## Conditions and Notes for Approval

C : Conditions for approval N : Notes attached to conditions

- C 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.

Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.

- C 2. Unless otherwise approved in writing by the Department, any telecommunications cabinet, mounted equipment or telecommunications structure must be removed from the land on which it is situated, within 6 months of it no longer being required for telecommunications purposes, and such land must be restored to its condition before the development took place, so far as is practicable.

Reason: To ensure that any redundant infrastructure is removed and to comply with Strategic Plan Infrastructure Policy 3.

- C 3. The development hereby approved shall not commence until further details of the antennas, dishes and remote radio heads to be installed have been submitted to and approved in writing by the Department. The development shall not be carried out unless in accordance with the approved details and shall be retained as such thereafter unless a variation or alteration is permitted under Schedule 2 of the Town and Country Planning (Telecommunications) Development Order 2019 (or any alteration/replacement of that order). Reason: To ensure appropriate use of the mast for telecommunication equipment.

- C 4. Notwithstanding the provisions of the Town and Country Planning (Permitted Development) Order 2012 (or any amendment or replacement of that order) no fencing, walling or gates shall be erected at the site other than as shown on the approved plans shall be erected.

Reason: to ensure the development is carried out in accordance with the approved plans in the interests of the visual amenity of the area.

- C 5. The proposed telecoms mast and affixed communication equipment here by approved shall be no higher than the stated 15m when measured from the concrete base as shown on plan referenced; IoM_35/014 Rev-D REASON To ensure the mast height is installed in accordance with the approved plans
- C 6. The proposed antennas, dishes and RRU shall be coloured to match the slimline lattice mast to which they are affixed and retained in perpetuity. REASON: To mitigate any visual impact.
- C 7. The temporary work area / fencing as shown on the drawing entitled, "Temporary Mast and Temporary Work Area" Ref; IOM_35/015_A shall be removed from the site within 2 weeks of the new mast being brought into use.

Reason: to prevent the retention on site of temporary works which would be detrimental to the visual amenity of the area.

This application has been recommended for approval for the following reason.

The proposed application is not considered to harm the use and enjoyment of neighbouring properties nor would it result in any adverse impact upon this part of the Industrial estate and would comply with Spatial Policy 2, General Policy 2, Environmental Policy 22; and Infrastructure Policy 3 of the Isle of Man Strategic Plan 2016.

Plans/Drawings/Information; This decision relates to drawings and supporting information received on 16 October 2024 referenced; IOM_35/010-A

- IOM_35/012-D
- IOM_35/013-A
- IOM_35/014-D
- IOM_35/015-A
- IOM_35/016-A
- IOM_35/017-A _________________________________________________________________

Right to Appeal

It is recommended that the following organisations should NOT be given the Right to Appeal: Ramsey Town Commissioners - no objection Highways Services - No Objection

_________________________________________________________________ Officer’s Report THE SITE

1.1 The application site is a small parcel of land identified in red that sits to the northern corner of the shipyard boat builders and workshop building within the wider area of Shipyard and slipways. The broader area sits on a peninsula that is surrounded by seawater/ harbour on three sides.

1.2 The site measurers 7.4m x 3.6m which currently contains a concrete hardstanding with a 15.3m monopole with 3 panel antennas within the shroud and two dishes. The immediate site is fenced off with 1.8m high steel mesh fencing and a 1.0m wide access gate. Within the compound is the monopole and two associated communications and electrical cabinets. This site is used by Sure Mobile who is also the applicant. THE PROPOSAL

2.1 Planning permission is being sought for the replacement of the current 15.m high monopole and in its place the installation of a new 15 meter high slim line lattice tower on the existing concrete slab foundation. The tower would be a triangular shape consisting of three tubular columns with supporting bracing forming the overall structure with a plain grey colour of the manufacturer's galvanised finish. - 2.2 Mounted to the lattice tower would be: 3 x panel antennas towards the top of the mast, 3 AAU's antennas and below this are; 6x RRU's and two 600mm dia dishes with associated ground equipment cabinets and two equipment cabinets on the existing concrete base. None of the equipment would be higher than the top of the 15m lattice tower. - 2.3 At present the specification of the 'antennas' are not known but the agents confirm; "Equipment Cabinets & Antenna sizes/locations and quantities are indicative as the final vendor decision has not yet been made, sizing will be confirmed with planning ahead of installation". - 2.4 The applicant notes; " The proposed structure will be capable of supporting multiple panel antennas, providing 2G, 3G and 4G/4G+ coverage in the area along with capability to support next generation mobile antenna technology, tower mounted remote radio heads (RRHs) will also be mounted near the new antennas, these are required to support MIMO* on the network…The new proposed structure will also support smaller dishes known as microwave links used as transmission links for the site back to the Sure core network, the proposed design includes 1 microwave link, the size/location of the dish on the included drawings for this application are indicative until a final vendor decision has been made, final sizes will be confirmed with planning ahead of installation. The current structure is incapable of supporting the next generation of mobile technologies, this is due to the current structure failing the wind loading assessment that we have had carried out based on the new equipment specifications, as equipment is getting heavier in some cases and it is also moving to tower mounted kit, rather than being in radio cabinets at the base of the structure". - 2.5 The application has been submitted by one of the Island's licensed operators (Sure Mobile) and is accompanied by a certificate of compliance with the World Health Organisation's ICNIRP guidelines for public exposure. (ICNIRP - "International Commission on Non-Ionising Radiation"). Signed 30 September 2024. - 2.6 As part of the proposal, the applicants intend to erect a temporary 8m high mast with 2 panel antennas on a trailer while the existing site is decommissioned, removed and the new installation (as per this application) undertaken. This mobile telecoms trailer will feature all the equipment cabinets to operate and will not require any hardstanding or excavation works to install. Equally it will be fenced off with Harras fencing. The proposed location of this is to the immediate north of the site on the boat parking area. PLANNING HISTORY

3.1 06/02061/B - Installation of a 15.3m high monopole mast with associated equipment cabinets. Approved.

## PLANNING POLICY LOCAL PLAN

4.1 The application site is identified as 'Light Industrial Use' under the Ramsey Local Plan Order

1998. The site is not within a Conservation Area. The site is prone to High Tidal Flood Risks.

4.2 The site is not within a Conservation Area but is prone to High Tidal Flood Risks. There are no registered trees or registered tree groups boarding the site. STRATEGIC PLAN - 4.3 The following policies from the 2016 Strategic Plan are considered pertinent in the assessment of this application;

Para - 1.6 Planning Guidance from the UK and the EU 1.6.1 "The Island has a close relationship with the UK, within which there are land-use planning systems which have the same general purpose as, and much in common with our own system. We also have indirect links with the European Union. Accordingly, where unusual matters arise, or where there is no Manx guidance, it will often be appropriate and helpful to have regard to legal judgments or advice published in the UK or the EU".

Strategic Policy

- 1 Development should make the best use of resources (c) Spatial Policy
- 2 Named service centre (Ramsey) 5 New development will be located within defined settlement. General Policy

- 2 General Development Considerations (b,c,g,m)

Environment Policy 22 (iii) Safeguarding the environment and/or the amenities of surrounding properties

Infrastructure Policy

- 3 Need for communications infrastructure versus environmental impacts

The text preceding Infrastructure Policy 3 is an important consideration where it states in paragraph 11.9.2; o "The maintenance and improvement of these systems is likely to require the provision of new infrastructure; infrastructure required by private telecommunications operators is likely to be more extensive. It is important that a balance be struck between the need for new, evolving communications systems to satisfy residential and business demand and the impact that the necessary infrastructure will have upon the environment. New communications development should be in accordance with the provisions of this plan".

## OTHER MATERIAL CONSIDERATIONS;

4.6 Our Island Plan 2022, set the general direction of the islands Government current political administration with a general direction to improve the current infrastructure to facilitate more economic development as a priority for people, communities and business. This strategy gives a strong evidence base, highlighting the clear economic aspirations in order to achieve the Island overarching goals moving forward. Within the section entitled "Outstanding lifelong learning and development opportunities for all" the plan says; "Ensure that public services are increasingly digitally-enabled, and residents have access to fast, reliable internet via the Island's National Broadband Plan to create enhanced opportunities for learning in the Digital Age." - 4.7 The Isle of Man government has an overarching series of strategies and policies that are considered materially relevant to the assessment of this application. This includes the Isle of Man Government Climate Change Plan 2022-2027; which promotes a more sustainable approach to living and working, one of which is remote working. - 4.8 National Telecommunications Strategy 2018

"The National Telecoms strategy (NTS), laid out in six themes, looks to set a direction of travel by which the Island's telecom infrastructure can be recognised as being world class. The Government has made it clear that enhanced telecoms infrastructure is a top priority… The benefits will be available to all our residents and businesses on the Island and will underpin and support economic growth". This document talks broadly about telecoms on Island but geared more towards supporting the delivery of fibre broadband, next generation technologies and integration of 5g mobile connectivity. One of the deliverable objectives from page 30 notes; "Planning and wayleave legislation facilitates the introduction of new telecoms infrastructure such

- as 5G which we are an early adopter of".

4.9 National Broadband Plan (Mobile) As part of the NTS (above), support is given to improve mobile networks. The Island currently has 99% 4G and 75% 4G+ coverage and this plan seeks to facilitate the improvement and distribution of more cell sites to allow for 5g integration." DfE will develop a strategy in partnership with operators and the Communications Commission in support of 5G by June 2019" (page19). - 4.10 KPMG - Our big Picture Evidence base report phase 1 - 16 December 2021; Para 4.9 (page 147) - "Analysis suggest that the overall quality of internet connectivity of the Island is not keeping pace with competitor jurisdictions, such as Jersey and there has been a decline in satisfaction regarding the quality of telecommunication services". - 4.11 IOM Economic Strategy November 2022; Over the next 10-15 Years, within the economic strategy is a broad Initiative for the Island to be; "Business-focused digital and technology adoption and infrastructure investment" and with the added benefit for residents and a growing population. (Document Ref; GD No. 2022/0080)

REPRESENTATIONS (this report only contain summaries - full reps can be read online)

5.1 Ramsey Town Commissioners (25/10/24) requested more time to comment until after 20th November. Confirmed no objection (21.11.24)

5.2 Highways Services do not object (24/10/24) ASSESSMENT - 6.0 The main issues to consider in the assessment of this planning application are as follows:

- - Principle of development (SP2, Stp1c, SP5)
- - Necessity (IP3)
- - Design (GP2b)
- - Visual impact (GP2c, IP3)
- - Impact upon residential amenity (GP2g)
- - Public Health (Ep22, Gp2m)
- - Other matters

PRINCIPLE

6.1 The application is submitted by Sure Mobile, essentially to improve the available mobile coverage in the parish of Ramsey that consists a mixture of residential areas and some industrial. The principle would loosely be seen to assist with compliance to Sp2 as the site is within the identified settlement boundary of Ramsey and could assist with remote employment workings. Stp1c is adhered to as the applicants are utilising a previous telecoms site and the existing infrastructure and facilities in this area (albeit replacing the supporting mast and newer equipment).

6.2 The proposed installation will have the capabilities to address both indoor and outdoor coverage demands within the surrounding area, whilst significantly increasing the level of coverage within the immediate locality area as demonstrated as part of the submission. The site sits within the defined settlement boundary of Ramsey and is within an area that is designated for development which helps ensure compliance with Sp2 and SP5 being zoned for development.

The proposals also reflects the investment and modernisation of communications equipment on site which is sought as part of the overall Island Economic Strategy.

NECESSITY

6.3 In favour of the proposals is Infrastructure Policy 3 and its supporting text which advises that the maintenance and improvement of the Island's telecommunications systems will necessitate a balance to be struck between the need for new and evolving communications systems, particularly to satisfy the needs of residential and business demand, and the impact of such required development upon the environment. - 6.4 The proposed mast has been designed to have increased structural strength, enabling it to support next generation equipment along with future network enhancements which is directly supported by the Isle of Man Governments 'Island Plan' and supporting strategies feeding off this document which has a vision of a digitally connected Island, that supports a tech enabled and future ready jurisdiction. This will ensure the surrounding areas can benefit from greater network capacity and service due to these improvements and would align with the National Telecommunication strategy and its inherit National Broadband Plan for Mobile network expansion and its infrastructure. - 6.5 The principle of development also further receives support from the Climate Change Plan 2022-2027 through improved network infrastructure that would allow for increased levels of home/remote working within the wider residential area. The wider residential catchment here is an important consideration, particularly given the Government's strategy for remote workings and the agent notes; "Good connectivity is vital to support this strategy and ensuring that areas of the island, have high-capacity reliable mobile services to access the latest in technology is therefore key". - 6.6 The overall "need" for the proposal to support the expansion of electronic communications networks, including next generation mobile technology can be substantiated in this instance and works towards the overall Government objectives to enhance the level of connectivity through the investment and modernisation of communications equipment. This will result in the provision of newer and faster technology as part of the Islands communication goals through the National Telecoms Strategy, which is also part of the overall Island Economic Strategy (which both carry material weight) which advances towards 4g+,5g mobile, or its replacement to meet the growing technological demands on mobile services across the Island. As such this aspect would be read in accordance with first part of IP3 of the IOM Strategic Plan. DESIGN - 6.7 The design of the mast would see a slim line tubular, triangular shaped 'structure' with diagonal bracing through which the sky behind would be partially visible, whereas the existing monopole is a solid tapered structure, which helps the new mast to blend in with its surroundings. However, to the upper proportions of the mast would be affixed with various transmitting equipment which could emphasise its visual appearance. It is noted the dimensions of the communication equipment are indicative in the sizes and a 'worst case' scenario but the number of antennas/ panels/ dishes affixed to the lattice tower would remain as proposed. - 6.8 The current 'structure' it is understood to be incapable of supporting the next generation of mobile technology of AAU's and RRU's antennas and the current structure failed the wind loading assessment that has been carried out based on the new equipment specifications. - 6.9 The level of finish of the antennas and mast is an important consideration as it was proposed to be untreated colour of galvanised steel / grey that would be read against the skyline. It is noted that the antennas attached to the mast would be no higher than the top of the pole and can be conditioned as such, but it is important that any communications equipment and antennas are colour coded to match the mast to mitigate any visual impact and they are all read as one unified colour.

6.10 This can be secured through an appropriate worded condition to help reduce the visual impact of the mast and equipment, whilst providing sufficient signal strength for customers to take advantage of a range of Sure Telecom services. In terms of colour it was discussed with the applicants that a grey colour would be preferable as the backdrop here when viewed from public vantage points could be read against the industrial nature of the site and potentially ships masts. VISUAL IMPACT - 6.11 The specific siting of the proposed mast and its antennas, essentially the upper proportions could be visible from within the industrial estate, especially being at 15m high. The current mast when looking up is marginally higher than the existing buildings in the area and this proposal at 15m would sit (approx. 7m higher) above the ridge line of many of the buildings in the immediate area. - 6.12 The site visit also confirmed the close proximity of the existing mast to the buildings side elevation, the presence of yachts and their vertical / taller masts immediately adjacent to the site, giving and the use of the area as a harbour storage area. It is noted the above are all a grey galvanised in colour and as is the proposed mast. Only the antennas and dishes should be colour coded to match the proposed lattice mast to enable he entirety to be read as one and should not be white in colour, mainly to ensure a uniformed finish and to mitigate any further visual impact. - 6.13 When considering any visual impact, it has to be noted many of the glimpsing views when viewed from the public highway are read amongst the back drop of the building and taller yachts masts which are read against the sky line. - 6.14 The agents have noted in their supporting statement; "We believe that the visual impact of the proposed replacement structure will be minimal, due to the structure type, having opted for a slim line lattice as the replacement we believe that the structure will be less visually intrusive than the current structure due to the fact that it will no longer be a solid structure, but rather one that you can essentially look through, helping it blend in with the surroundings". As such this is an agreeable approach as a replacement mast to mitigate visual impact. - 6.15 With regard to the associated cabinets their visual impact would be negligible and would not be seen as in conflict with policy leading to an adverse visual impact, over and above given the levels of existing development on the wider site and would be read in the same context as the mast. - 6.16 On balance, the benefits of providing the required equipment to increase network coverage are considered to outweigh the limited visual harm resulting from the development, particularly in the context of the Government's ambition to improve public infrastructure and promote remote/home working as part of the Government's plan to achieve net zero status for the Island by 2050. Equally it is also noted the local authority / commissioners here supported the application. - 6.17 On this basis, it is considered that the proposal would not create any additional visual harm or intrusion into the site and surrounding rural area and would conform to those parts of Strategic Policy 2, General Policy 2(b,c) and Infrastructure Policy 3. RESIDENTIAL AMENITY - 6.18 The proposed siting within an industrial estate ensures the mast is considerable distance (excess of 20m) from any dwelling house. The nearest being 'Marsden Terrace' located approx. 65m to the north to the rear elevation of the nearest dwelling house in the terrace (No.12). From here the intervening industrial building sits between the mast and those properties means in theory, only from the upper floors of those properties could have distant views across the roof scape of the building towards the mast be achievable. Whilst noting the above, and this application is for a replacement of an existing mast of the same height, if there are views of the proposals from those dwelling houses, this would be a distant view and the loss of a view or interruption of a view is not a material planning consideration. Any views would be read

amongst the masts of the yachts in the harbour area. It is noted that has not been any objections to the proposal. As such the proposals are not considered to have any detrimental impact upon neighbouring amenities and is therefore compliant with General Policy 2(g) and Environmental Policy 22.

## PUBLIC HEALTH

6.19 In terms of health issues associated with a telecommunication mast, it is mainly their antennas and broadcasting potential in proximity to residential dwellings or business areas that can publically raise concerns. On the Isle of Man there are no specific guidelines in how to deal with such concerns in relation to radio spectrum and electromagnetic fields used to deliver mobile communications. The regulating body on the IoM is (Communications and Utilities Regulatory Authority (CURA) who has responsibility for the licensing and regulation of telecommunications and broadcasting under the Telecommunications Act 1984, the Radio Masts Regulation Act 1988, and the Broadcasting Act 1993. - 6.20 However, guidance in the United Kingdom (since replaced with less specific guidance) expressly advised that where a proposed telecommunications installation conforms to the recommendation of The Independent Expert Group on Mobile Phones ("The Stewart Report") and the guidelines for the public exposure set by The International Commission On Non-Ionising Radiation Protection (ICNIRP), that addresses the protection of humans exposed to radiofrequency electromagnetic fields (RF) in the range 100 kHz to 300 GHz. Then the Local Planning Authority should have no concerns with regard to health and safety issues from the antennas. - 6.21 The application is accompanied by a declaration certificate of compliance with the World Health Organisation ICNIRP guidelines for public exposure, and the 'Health and Safety at Work Inspectorate' is responsible for the monitoring of telecommunications installations to ensure compliance with the ICNIRP Guidelines. These declarations are health and safety assurances, provided by telecoms companies, when they want to install a new telecommunications mast, or upgrade an existing mast. - 6.22 Given the broad support from the IoM National Telecoms Strategy and the Island Plan which all seeks advancements in further use of mobile technology to meet the future demands,

at present based on the above, there are no concerns relating to the safety of the general public are therefore raised. In this respect, the proposal is compliant also with GP2(m).

6.23 Equally the proposals would comply with EP22 as it would not be seen to create any statutory nuisance through vibration, odour, noise or light pollution during its operation. OTHER - 6.24 The proposed equipment affixed to the mast are shown on the plans with indicative sizes. As such, whilst the principle of the telecom equipment affixed to the mast has been shown with the quantity of units and type of antennas and dishes, those specific details can be conditioned to ensure specifics and dimensions are submitted prior to commencement on site to ensure the mast is appropriately utilised for telecommunication equipment as shown on the plans and appropriately assessed above.

## - 7.0 CONCLUSION

7.1 Whilst it is acknowledged that the height of the lattice tower will have a limited visual impact in the existing rural setting, it is considered that the proposal would not create any additional visual harm or intrusion into the site and surrounding rural area.

7.2 The benefits of providing the required equipment to increase network coverage are considered to outweigh the limited visual harm resulting from the development, particularly in the context of the Government's ambition to improve public infrastructure and promote remote/home working. This would also work towards the Government's plan to achieve net zero

- status for the Island by 2050 and would conform to the Island Plan and the National Telecoms Strategy.
- 7.3 On balance the proposal would comply with those parts of Strategic Policy 1c, Spatial Policy 2&5, General Policy 2(b,c,g,m), Environment Policy 22 and Infrastructure Policy 3 of the Isle of Man Strategic Plan 2016, and is recommended for approval with conditions.

## - 8.0 RIGHT TO APPEAL AND RIGHT TO GIVE EVIDENCE

8.1 The Town and Country Planning (Development Procedure) Order 2019 sets out the process for determining planning applications (including appeals). It sets out a Right to Appeal (i.e. to submit an appeal against a planning decision) and a Right to Give Evidence at Appeals (i.e. to participate in an appeal if one is submitted).

8.2 Article A10 sets out that the right to appeal is available to:

- o applicant (in all cases);
- o a Local Authority; Government Department; Manx Utilities; and Manx National Heritage that submit a relevant objection; and
- o any other person who has made an objection that meets specified criteria.

8.3 Article 8(2)(a) requires that in determining an application, the Department must decide who has a right to appeal, in accordance with the criteria set out in article A10. - 8.4 The Order automatically affords the Right to Give Evidence to the following (no determination is required):

- o any appellant or potential appellant (which includes the applicant);
- o the Department of Environment, Food and Agriculture, the Department of Infrastructure and the local authority for the area;
- o any other person who has submitted written representations (this can include other Government Departments and Local Authorities); and
- o in the case of a petition, a single representative.

8.5 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given the Right to Appeal.

I can confirm that this decision has been made by the Acting Head of Development Management in accordance with the authority afforded to that officer by the appropriate DEFA Delegation and that in making this decision the Officer has agreed the recommendation in relation to who should be afforded interested person status and/or rights to appeal.

Decision Made: Permitted Date: 25.11.2024 Determining officer

Signed : A MORGAN Abigail Morgan Acting Head of Development Management

Customer note This copy of the officer report reflects the content of the office copy and has been produced in this form for the benefit of our online service/customers and archive record.

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